Gwendolyn Jackson and Billy Jackson v. Cach, Llc

ACCEPTED 14-15-00648-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/27/2015 11:04:14 PM CHRISTOPHER PRINE CLERK CAUSE NO. 1049215 FILED IN CACH, LLC, § IN THE COUNTY CIVIL COURT 14th COURT OF APPEALS Plaintiff, § HOUSTON, TEXAS § 8/27/2015 11:04:14 PM § CHRISTOPHER A. PRINE § Clerk v. § AT LAW NUMBER 3 § § GWENDOLYN JACKSON and § BILLY JACKSON, § Defendants. § HARRIS COUNTY, TEXAS NOTICE OF APPEAL TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Gwendolyn Jackson and Billy Jackson on this 30th day of July 2015, appearing by and through the undersigned counsel of record, and pursuant to the authority of the Texas Rules of Appellate Procedure, filing this Notice of Appeal. In support thereof, Gwendolyn Jackson and Billy Jackson would show the Court the following: 1. Gwendolyn Jackson and Billy Jackson desire to appeal to either the First or Fourteenth Court of Appeals, the Final Order entered in Cause No. 1049215; Cach, LLC, Plaintiff v. Gwendolyn Jackson and Billy Jackson, Defendants, which was signed by the Presiding Judge of the County Civil Court At Law Number 3 in Harris County, Texas on July 1, 2015. 2. Gwendolyn Jackson and Billy Jackson file this appeal because they are directly and adversely affected by the Final Order. 3. Appellants seek to render void and unenforceable, the trial court’s order of July 1, 2015, which awarded a judgment in favor of Plaintiff Cach, LLC for money damages Plaintiff claims Defendants Gwendolyn Jackson and Billy Jackson caused. Notice of Appeal Pg. 1 4. The trial court signed the Final Order on July 1, 2015, thereby making the deadline to file a notice of appeal thirty (30) days from that date pursuant to Texas Rule of Appellate Procedure 26.1. Appellant’s Notice of Appeal is timely as it is within the time allowed for filing the notice of appeal. Tex. R. Civ. P. §4. 5. Appellant also requests suspension of enforcement of the judgment rendered by the Final Order of July 1, 2015, pending appeal. 6. Pursuant to Rule 34.5 of the Texas Rules of Appellate Procedure, Appellant respectfully requests that an undesignated copy of the Clerk's Record be included in the Appellate Record. 7. Contemporaneously with the filing of this Notice of Appeal, Gwendolyn Jackson and Billy Jackson are serving notice of the appeal on all parties to the Final Order. WHEREFORE, PREMISES CONSIDERED, Gwendolyn Jackson and Billy Jackson respectfully pray that this Notice of Appeal be filed amongst the papers in the above-styled and numbered cause and then assigned to either the First or Fourteenth Court of Appeals so that it may be heard. Additionally, Appellants pray for such further relief either at law or equity, to which they may prove themselves justly entitled. Respectfully submitted, /s/ Taura D. Spates Taura D. Spates Texas Bar No. 24071745 P.O. Box 742393 Houston, TX 77274 (713) 203-3861 Ph (281) 206-2660 Fx tauraspates@yahoo.com ATTORNEY FOR APPELLANTS, GWENDOLYN JACKSON AND BILLY JACKSON Notice of Appeal Pg. 2 CERTIFICATE OF SERVICE This is to certify that the above and foregoing Notice of Appeal has been served by delivery of a true copy on the 30th day of July 2015 to Plaintiff Cach, LLC by facsimile transmission to (713) 782-9664 and by electronic transmission as follows: Richard E. Clark rclark@rclegal.net Fallon Hamilton fhamilton@rclegal.net Shaun G. Brown sbrown@rclegal.net /s/ Taura D. Spates Taura Spates Notice of Appeal Pg. 3